Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 44
Page 1
... levy could be based and that no further collection action should be taken , P's challenges to the pro- posed levy are moot . Held , further , this Court lacks jurisdic- tion in this collection review proceeding to determine an over ...
... levy could be based and that no further collection action should be taken , P's challenges to the pro- posed levy are moot . Held , further , this Court lacks jurisdic- tion in this collection review proceeding to determine an over ...
Page 2
... levy.1 Background When she petitioned this Court , petitioner resided in Chi- cago , Illinois . Stipulated Decision for 1992 Taxable Year On June 5 , 1997 , in a prior deficiency proceeding involving petitioner's 1992 taxable year ...
... levy.1 Background When she petitioned this Court , petitioner resided in Chi- cago , Illinois . Stipulated Decision for 1992 Taxable Year On June 5 , 1997 , in a prior deficiency proceeding involving petitioner's 1992 taxable year ...
Page 3
... levy , or notice of jeopardy levy with respect to taxable year 1992 . 5 The record does not otherwise conclusively establish how the $ 4,992.70 assessed balance was calculated . 6 The Notice of Determination also sustained a separate ...
... levy , or notice of jeopardy levy with respect to taxable year 1992 . 5 The record does not otherwise conclusively establish how the $ 4,992.70 assessed balance was calculated . 6 The Notice of Determination also sustained a separate ...
Page 5
... levy with respect to her 1992 taxable year should proceed . She also challenged her liability for the 1992 deficiency and asso- ciated interest on the ground that respondent had failed to make timely notice and demand for payment ...
... levy with respect to her 1992 taxable year should proceed . She also challenged her liability for the 1992 deficiency and asso- ciated interest on the ground that respondent had failed to make timely notice and demand for payment ...
Page 6
... levy " . Sec . 6330 ( c ) ( 2 ) ( A ) . The taxpayer is also entitled to challenge " the existence or amount of the underlying tax liability ” if he or she " did not receive any statutory notice of 9 Neither party originally argued that ...
... levy " . Sec . 6330 ( c ) ( 2 ) ( A ) . The taxpayer is also entitled to challenge " the existence or amount of the underlying tax liability ” if he or she " did not receive any statutory notice of 9 Neither party originally argued that ...
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Common terms and phrases
9th Cir adjustments Admin administrative affd amended amount Anglo-Am Antarctica Appeals officer apply assessment Brand X capital loss Chevron claim closing agreement coal Commis Commissioner community property laws computation Congress conservation easement Court of Appeals December 31 deficiency notice Direct Tea Trading disputed regulations election entitled Fairfax County Federal income tax Federal tax foreign corporation GATT rate Grist Mill property gross income hearing Income Tax Regs income tax return Internal Revenue Code Internal Revenue Service interpretation issue jurisdiction Lee Ranch legislative history levy LIFO limited majority mark-to-market ment method of accounting Natl notice of determination ous payment 99.00 overpayment interest parties petition petitioner petitioner's Planegger Proced provides real property reasonable refund relevant text relief Rept request respondent respondent's Revenue Act rule Secretary section 233 sioner spouse Stat statute statutory Subsequent miscellane supply contracts supra T.C. Memo Tax Court tax lien taxpayer tion United Zapara